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Challenges Faced by NGOs in Myanmar

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Myanmar’s restrictive policies pose significant challenges to non-governmental organizations (NGOs) operating in the country. The government’s proposed new law and the potential consequences of being listed as a high-risk jurisdiction by the Financial Action Task Force (FATF) exacerbate these challenges.

Challenges Faced by NGOs


The following are some of the key challenges faced by NGOs in Myanmar:

Restrictive NGO Laws

  • Mandatory registration with increased operational restrictions.
  • Curbing humanitarian access and placing unreasonable levels of scrutiny on NGOs.
  • Additional administrative requirements and data protection violations hinder implementation of humanitarian activities.

Physical Access Barriers

  • Movement restrictions, delays in travel authorizations, and checkpoint investigations impede physical access to communities in need.

Interference in Operations

  • Additional administrative requirements and data protection violations hinder the implementation of humanitarian activities.

Safety and Security Risks for Staff/Volunteers

  • The intensification of bureaucratic and administrative impediments exposes individual staff to heightened safety and security risks.

Consequences of FATF Listing


The potential listing of Myanmar as a high-risk jurisdiction by the FATF could have devastating consequences:

Devastating Humanitarian Impact

  • Blacklisting would deny access to basic services, such as food, shelter, health, and education, to 14.4 million people in need.

NGO Suspension or Withdrawal

  • Overly restrictive NGO laws have resulted in the suspension or withdrawal of NGOs from certain geographies.

Requests for Support from FATF Member States


To avoid these severe impacts on vulnerable communities, we request that FATF member states:

Reconsider Listing Myanmar as a High-Risk Jurisdiction

  • To ensure that severe impacts are avoided and legitimate NGO operations can continue uninterrupted.

Refrain from Compelling States to Adopt Measures that Jeopardize Legitimate NGO Operations

  • Review due diligence requirements and issue additional guidance as appropriate.

Act Proportionately Based on Identified Risks and Threats

  • Implement systemic and sustainable safeguards to mitigate unintended negative effects of FATF actions.

Issue a Public Statement Emphasizing the Need for Preserving and Protecting Legitimate NGO Activities

  • To ensure continuity of urgent life-saving aid delivery to the people of Myanmar.

Additional Requests


We also request that:

Recognize and Enable Both Formal and Informal Financial Aid Modalities in Myanmar

  • Avoid de-banking and financial exclusion by considering alternative money transfer modalities widely used and accepted in other regions with sanctions.